Arcus Infrastructure Partners (“we” or “us”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be used by us. It also describes the choices available to you regarding our use of your personal data and how you can access and update this information.
Please read the following carefully to understand how we will treat your personal data.
In these provisions:
“Arcus” means Arcus Infrastructure Services LLP and its affiliates from time to time;
“Content’ means all pages, screens, information and materials included in or accessible through this Website (including any content available on any email or SMS services);
“You”, “your” and “yours” means you, the person(s) accessing this Website and the party on whose behalf you are doing so; and
“We”, “us” and “our” means Arcus.
Any information you provide will be controlled by Arcus Infrastructure Services LLP and/or Arcus European Investment Manager LLP (“we”, “us” and “our”). We will ensure that all information that you provide to us is treated in confidence and in accordance with our obligations under the General Data Protection Regulation. We will not disclose such information to any third parties except (a) where required or permitted by law; or (b) where your consent has been received. Your details will not be given to third parties for marketing purposes.
WHAT IS PERSONAL DATA
Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
INFORMATION WE COLLECT FROM YOU
We may collect the following personal data from you:
- Contact information such as name, email address, mailing address, phone number;
- Information about your business role, such as job title and company name;
- Information about your interests in our services and products; and
- Details of your visits to this Website and the materials and information that you access. Our website may also collect your device’s unique identifier, such as an IP address.
We may use this information for our legitimate business interests, including to:
- Send you requested product or service information;
- To fulfil contractual obligations we may have with you;
- Respond to queries and customer service requests or concerns;
- Administer and manage delivery of our services and products to you;
- To provide you with information by letter, SMS, telephone and/or email on information that you request from us or we feel may be of interest to you, where you have consented to be contacted for such purposes;
- To conduct checks that help prevent fraud and money laundering;
- To notify you about changes to our services;
- Improve our Website and marketing efforts; and
- Comply with our legal obligations.
We may disclose your personal data to other Arcus affiliates for the purposes stated above. Where we do so we will always use every reasonable effort to ensure your personal data is safeguarded to the same standards to which we are subject to. We may also disclose your personal data to agents and service providers (within and outside the European Economic Area) of Arcus for such purposes, or if we or any affiliates are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply these terms and conditions or other agreements that may be in place with you, or to protect the rights of Arcus or its clients. We do not sell your personal data to third parties for them to market their services to you.
Your personal data may also be shared with:
- Fund and managed accounts associates: the fund and managed accounts parties may share your personal data with associates, related parties and members of their group. This is to manage our relationship with you;
- Fund and managed account managers, depositaries, administrators and investment advisors: to enable us to deliver the services you require, support and administer investment related activities and comply with applicable laws and regulations;
- Tax authorities: to comply with applicable laws and regulations, where we are required to by EEA tax authorities (who, in turn, may share your personal data with foreign tax authorities) and where required by foreign tax authorities, including outside of the EEA; and
- Service providers: to deliver the services you require and to comply with applicable legal and regulatory requirements.
In exceptional circumstances we will share your personal data with competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in any country or territory and organisations and agencies when we are required to do so by law.
By using the Website, you consent to us using your personal data in accordance with this policy and you confirm that all data provided by you is accurate.
You have the following rights:
- Ask whether Arcus processes your personal data;
- To object to direct marketing and in certain circumstances to have the data rectified or blocked;
- If your personal data changes, or if you no longer desire our services, you may ask to have your personal data corrected, amended, removed or deleted;
- To request us to correct any inaccurate personal data that is held;
- To withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
We work with third parties to research certain usage and activities on our Website on our behalf. No personal information about you is shared, however in the course of conducting this research these third parties may place a unique ‘cookie’ on your browser.
This Website uses Google Analytics (http://www.google.com/analytics/) for website analytics purposes – meaning that we use them to see how many visitors come to the Website, the pages that generate interest and the links that visitors most often click on (amongst other things).
In addition, we use two specific types of cookie on this Website:
- Session cookies, which are temporary cookies that remain in the cookie file of your computer until you close your browser (at which point they are deleted); and
- Persistent or stored cookies that remain permanently on the cookie file of your computer.
HOW TO MANAGE COOKIES
You can set your web browser to disable cookies or to inform you when a website is attempting to add a cookie. You can also delete cookies that have previously been added to your computer’s cookie file. You should be aware, however, that if you disable cookies the functionality of this website may be affected. Disabling cookies will usually result in also disabling certain functionality and features of this site. It is therefore recommended that you do not disable cookies.
Please visit http://www.allaboutcookies.org/manage-cookies/ to discover how to disable and delete cookies
WEB BEACONS AND SPOTLIGHT TAGS
This Website may contain electronic images, known as web beacons or spotlight tags. These enable us to count users who have visited certain pages on the website. Web beacons and spotlight tags are simply tools used to obtain generic information about the web pages visited. They are not used to obtain information about specific users.
The security of your personal data is important to us. We follow industry standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the internet, or method of electronic storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.
We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.
We will generally retain information about you throughout the life cycle of any investment you are involved in, some personal information will be retained after your relationship with us ends.
As a general principle, we do not retain your personal data for longer than we need it.
We will usually delete your personal information (at the latest) 7 years after your relationship with us has ended, this is due to fulfilling regulatory requirements.
You can lodge a complaint about our processing of your personal data with the body regulating data protection in your country. A list of the EU data protection authorities is available by clicking this link http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.
CHANGES TO THIS POLICY